Certified Information Privacy Manager (CIPM) — Question 104
SCENARIO -
Please use the following to answer the next question:
As they company’s new chief executive officer, Thomas Goddard wants to be known as a leader in data protection. Goddard recently served as the chief financial officer of Hoopy.com, a pioneer in online video viewing with millions of users around the world. Unfortunately, Hoopy is infamous within privacy protection circles for its ethically questionable practices, including unauthorized sales of personal data to marketers. Hoopy also was the target of credit card data theft that made headlines around the world, as at least two million credit card numbers were thought to have been pilfered despite the company’s claims that “appropriate” data protection safeguards were in place. The scandal affected the company’s business as competitors were quick to market an increased level of protection while offering similar entertainment and media content. Within three weeks after the scandal broke, Hoopy founder and CEO Maxwell Martin, Goddard’s mentor, was forced to step down.
Goddard, however, seems to have landed on his feet, securing the CEO position at your company, Medialite, which is just emerging from its start-up phase. He sold the company’s board and investors on his vision of Medialite building its brand partly on the basis of industry-leading data protection standards and procedures. He may have been a key part of a lapsed or even rogue organization in matters of privacy but now he claims to be reformed and a true believer in privacy protection. In his first week on the job, he calls you into his office and explains that your primary work responsibility is to bring his vision for privacy to life. But you also detect some reservations. “We want Medialite to have absolutely the highest standards,” he says. “In fact, I want us to be able to say that we are the clear industry leader in privacy and data protection. However, I also need to be a responsible steward of the company’s finances. So, while I want the best solutions across the board, they also need to be cost effective.”
You are told to report back in a week’s time with your recommendations. Charged with this ambiguous mission, you depart the executive suite, already considering your next steps.
You give a presentation to your CEO about privacy program maturity. What does it mean to have a “managed” privacy program, according to the AICPA/CICA Privacy Maturity Model?
Answer options
- A. Procedures or processes exist, however they are not fully documented and do not cover all relevant aspects.
- B. Procedures and processes are fully documented and implemented, and cover all relevant aspects.
- C. Reviews are conducted to assess the effectiveness of the controls in place.
- D. Regular review and feedback are used to ensure continuous improvement toward optimization of the given process.
Correct answer: C
Explanation
The correct answer is C because a 'managed' privacy program involves conducting reviews to evaluate the effectiveness of the controls in place, ensuring that they are functioning as intended. Options A and B describe varying levels of documentation and implementation, which do not specifically address the management aspect. Option D focuses on continuous improvement, which is beyond the basic management definition of assessing effectiveness.